Epstein Secrets

rtedly between Ms. Maxwell and third-party "influential" men whom she allegedly tried to set up on dates, and (b) a witness a woman who worked for Epstein between 2005-06 (after the conclusion of the charged conspiracy) whom the Government said it "may call" at trial. The Government asserted in the Le

ified] documentary evidence relating to the 4 EFTA00105960 charged crimes [and (ii)] her [unspecified] role in scheduling sexualized massages for Jeffrey Epstein with underage girls," apparently in 2005-06. This is hardly the type of "identiff ied]" evidence the Rule contemplates. What "documentary evidence"

RE TO COMPLY WITH THE RULE'S NOTICE REQUIREMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

e Letter makes clear that the witness worked for Mr. Epstein from 2005-06, after the conclusion of the charged

GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x GHISLAINE MAXWELL'S MOTION TO EXCLUDE ANY EVIDENCE OFFERED BY THE GOVERNMENT PURSUANT TO FED. R. EVID. 404(b) FOR FAILURE TO COMPLY WITH THE RULE'S NOTICE REQUIREMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 1

TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE I AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negot

UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO

during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

y the constitutional right to effective assistance of counsel and the express language of Rule 410 and Federal Rule of Criminal Procedure 11(0. FED. R. EVID. 410 (discussions made EFTA00301859 during plea negotiations are "not, in any civil or criminal proceeding, admissible against the defendant who

TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE 1 AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Pr

UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO

during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

the constitutional right to effective assistance of counsel and the express language of Rule 410 and Federal Rule of Criminal Procedure 11(0. FED. R. EVID. 410 (discussions made during plea negotiations are "not, in any civil or criminal proceeding, admissible against the defendant who .. . was a parti

numerous allegations, over the span of four years, that Ms. Maxwell participated in a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Pagel 0 of 38 Plaintiff, a public figure required to prove actual malice, liti

and sexual trafficking of minors. Her lawyers intended to prove the defamation claim solely by, in effect, "prosecuting" Ms. Maxwell as a proxy for Epstein. Plaintiff chose this course of action because even she admitted some of her public statements were false. Discovery in the case was correspondingl

ng her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Documen

) 27 Other Authorities U.S. CONST. amend. V 18, 27 U.S. CONST. amend. VI 18, 27 Rules Fed. R. App. P. 8(a)(2) 13 FED. R. Evm. 401 28 FED. R. EVID. 402 28 FED. R. EVID. 403 28 FED. R. Evm. 404(b) 28 iv EFTA00074908 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page7 of 38 Table of

Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed durin

cannot obtain as a matter of constitutional law. Mr. Epstein has performed his side of the bargain with the go

t did in subsection (3). There, Congress expressly provided for change-of-plea proceedings in federal court and "comparable state procedures." FED. R. EVID. 410(3). Congress did not provide for state court pleas in subsection (4) of the rule, and "where Congress includes particular language in one secti